Public Citizen, Inc. et al v. Louisiana Attorney Disciplinary Board et al

Filing 38

First Witness and Exhibit List by Scott G. Wolfe, Jr, Wolfe Law Group, LLC. (Reference: 08-4994)(Wolfe, Scott)

Public Citizen, Inc. et al v. Louisiana Attorney Disciplinary Board et al

Doc. 38

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA SCOTT G. WOLFE, JR.; and WOLFE LAW GROUP, L.L.C. | | | | Plaintiffs, | | v. | | LOUISIANA ATTORNEY | DISCIPLINARY BOARD; BILLY R. | PESNELL, in his official capacity as Chair | of the Louisiana Attorney Disciplinary | Board; and CHARLES B. PLATTSMIER, | in his capacity as Chief Disciplinary | Counsel for the Louisiana Attorney | Disciplinary Board's Office of Disciplinary | Counsel; | | Defendants. |

Master Docket: Civil Action No. 08-4451 Relates To: Civil Action No. 08-4994

Section F (Judge Feldman) Mag 2 (Mag. Judge Wilkinson)

PLAINTIFF'S EXHIBIT LIST NOW INTO COURT, through undersigned counsel, comes Plaintiff, Scott G. Wolfe, Jr., and Wolfe Law Group, LLC (hereinafter "Wolfe" or "Plaintiff"), who respectfully files this exhibit list: Plaintiff may introduce the following exhibits at the trial of this matter: 1. The websites, in PDF or other electronic format for display through the use of electronic displays, or as printed, listed in Plaintiff Scott Wolfe Jr.'s

Dockets.Justia.com

and Wolfe Law Group, L.L.C.'s Initial Disclosures, including the following unlisted sites: http://www.wolfelawrocks.com, http://www.constructionlienblog.com, http://www.scottwolfe.com, http://www.protectspeech.com, 2. Instructional materials and documentation about services from LinkedIn, YouTube, Google, Avvo, Twitter, Facebook, PicasaWeb, PR Web, Yahoo, Microsoft, Scribd, Knol, JDSupra, Feedburner, FriendFeed, Plaxo, Construction Law Monitor, Construction Exchange, LawGuru, and The American Bar Association's Legally-Minded; 3. Instruction Videos and other web videos related to all of the abovementioned services, as well as the videos listed in the Plaintiffs' Initial Disclosures; 4. Online web advertisements and communications, and podcasts or videos, by Scott Wolfe Jr., and Wolfe Law Group, L.L.C. 5. Forms associated with the Rule 7.7 Evaluation process, as published at LSBA.org; 6. Transcripts from the Public Comment hearings in Baton Rouge, Lafayette, New Orleans and Shreveport conducted by the Louisiana State Bar Association; 7. Any and all exhibits introduced by either party in William H. Harrell, Jr., et al v. The Florida Bar, et. al, 08-00015, USDC Middle District of Florida.

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8. Any and all exhibits introduced by either party in James L. Alexander, et al v. Thomas Cahill, et al., 07-00117, USDC Northern District of New York. 9. Any and all documents listed by Defendants in their Rule 26(a) Initial Disclosures; 10. Any and all documents listed by Public Citizens, Inc., Morris Bart, Morris Bart, LLC, William N. Gee, III and William N. Gee, III, Ltd. in their Rule 26(a) Initial Disclosures; 11. Any and all documents produced by Plaintiffs in its response to Defendants' Request for Production of Documents; 12. Any and all documents produced by Defendants' in its response to Plaintiffs' Request for Production of Documents; 13. Any exhibit listed by any other party; Plaintiff reserves the right to supplement this exhibit list in accordance with rules of court.

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PLAINTIFF'S WITNESS LIST NOW INTO COURT, through undersigned counsel, comes Plaintiff, Scott G. Wolfe, Jr., and Wolfe Law Group, LLC (hereinafter "Wolfe" or "Plaintiff"), who respectfully files this witness list: Plaintiff's shall call or may call the following witnesses to testify at trial:

1. Any party listed in Plaintiff's Initial Disclosures; 2. Any party listed in Discovery responses of any party to this litigation, or called by the same; 3. Brian Oberkirch, facts and expert opinion regarding internet advertising, social networks; 4. Gyi Tsakalakis, AttorneySync, facts and expert opinion regarding internet advertising, online attorney advertising and social networks;. 5. C.J. Delery Enterprises, Inc., C.J. Delery, Dana Conner, client of Wolfe Law Group who located the firm through its Internet presence and/or online advertisements. 6. Bradley Electrical Services, L.L.C., Shawn and Danielle Bradley, client of Wolfe Law Group who located the firm through its Internet presence and/or online advertisements. 7. Bottom Line Equipment, L.L.C., Kurt Degueyter, client of Wolfe Law Group who located the firm through its Internet presence and/or online advertisements.

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8. Tasch, L.L.C., Jack Allen, client of Wolfe Law Group who located the firm through its Internet presence and/or online advertisements. 9. Aviva Cuyler, Founder, JD Supra, LLC, fact witness with regard to the JD Supra website and service, and involvement of firms like and including Wolfe Law Group with the service; 10. Scott Wolfe, Jr., Wolfe Law Group, L.L.C., Plaintiff and fact witness. 11. Josh King, Vice President and General Counsel, Avvo, Inc., fact witness with regard to the Avvo website and service, and involvement of firms like and including Wolfe Law Group with the service; 12. Chris Schultz, Voodoo Ventures, LLC, facts and expert opinion regarding internet advertising, social networks;

Plaintiff reserves the right to supplement this witness list in accordance with rules of court.

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Dated: February 3, 2009 Respectfully submitted, /s Scott G. Wolfe, Jr. Scott G Wolfe, Jr. (30122) Wolfe Law Group, LLC 4821 Prytania Street New Orleans, LA 70115 504-894-9653 Fax: [phone] Counsel for Plaintiffs Respectfully submitted, _________________________________ Ernest E. Svenson (La. Bar 17164) Svenson Law Firm, L.L.C. 123 Walnut Street, Suite 1001 New Orleans, LA 70118 Tel: [phone] Fax: [phone] Counsel for Plaintiffs _

CERTIFICATE OF SERVICE A copy of this motion was served electronically upon all counsel of record on this date: February 3, 2009.

/s Scott G. Wolfe, Jr. Scott G Wolfe, Jr. (30122)

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